Is my company still subject to the CSRD after the Omnibus?

The exact thresholds

• More than 1,000 employees — AND
• More than €450M net annual turnover
• Both criteria must be met (previously: 2 of 3, from 250 employees)
• Listed SMEs: fully exempt
• Assessed at group (consolidated) level

Non-EU groups are in scope only if they generate more than €450M net turnover in the EU and have an EU subsidiary or branch above €200M.

What it changes for your company

• If you are below both thresholds, you have no mandatory CSRD reporting for financial years starting on or after 1 January 2027.
• The value-chain effect still exists: large in-scope clients may ask you for ESG data. But the reform adds a value-chain cap — companies under 1,000 employees can refuse requests that go beyond the Voluntary SME Standard (VSME).
• Voluntary VSME reporting can still help you stand out with investors, lenders and large clients — useful even when you are exempt.

The timeline

• 18 March 2026 — Directive (EU) 2026/470 enters into force.
• By 19 March 2027 — Member States transpose the CSRD provisions into national law.
• FY2025–FY2026 — Wave 1 companies now out of scope may benefit from transitional national exemptions.
• 2028 — First reports for large companies still in scope (covering FY2027). Simplified ESRS — fewer data points — expected mid-2026.

What to do now

1. Run a scope check at group level against both thresholds (consolidated, not single-entity).
2. If out of scope: decide what ESG information you will still share with investors and clients, and through which channel — VSME is the reference.
3. If a large client over-asks: you can invoke the value-chain cap.
4. If still in scope: use 2026 to prepare — double materiality assessment and data inventory.